PRIVACY POLICY PATIENTS APP
1.INTRODUCTION
- 1.1. “We”/”Us”/”Our”/”Organisation” individually and collectively refer to Third AI Platforms Private Limited having CIN no. U74999DL2021PTC381786 and know that You as a user (‘You’, ‘Your’, ‘User(s)’) care about how Your personal information is used and shared, and we take Your privacy seriously. Please read the following to learn more about Our “Privacy Policy”/”Policy”. The Privacy Policy outlines the duration for which we retain Your information and the measures we take to protect your information. We ensure its safety in the process of rendering our Services or transferring it to Third-Party Service Providers in the course of their work through Our App(as defined in Our Terms of Use). By visiting or using [•] or any other linked pages, features, content, mobile applications, or any other Services offered from time to time by Us as an aggregator via our Third-Party Service Providers or in connection therewith (collectively, the “Application”/“Platform”/“App”), or by using the Services (as defined in our Terms of Use) in any manner, You acknowledge that You accept, and are subject to, the practices and policies outlined in this Privacy Policy;
- 1.2. HeaLink is a service provider and aggregator, which brings a plethora of fitness, medical, and wellness services under one roof. The Company is providing Services (as defined in Our Terms of Use) of Digitizing and Linking Decentralized Digital Health Care Delivery System. We are tying up with various Third-Party Service Providers and providing an Application to aggregate various third-party services. Our Services include the digital management of medical cases, booking appointments, creation of walk–in tokens, saving encrypted and secure medical information and records, creation and linking of ABHA, digital management of health lockers and health information, consent management, providing a facility for nutrition charts, workout charts, and diet charts via respective Third-Party Service Providers, business analytics, enterprise management, telemedical consults with doctors. We hold the sincere belief that You should always know what data We collect from You, the purposes for which such data is used, and that You should have the ability to make informed decisions about what data You want to share with Us;
- 1.3. This is why We want to be fully transparent about:
- 1.3.1. how and why We collect, store, share, and use Your personal data through the various capacities in which You interact with Us; and
- 1.3.2. the rights that You have to determine the parameters of this interaction.
- 1.4. This Privacy Policy is published in compliance with inter alia:
- 1.4.1. Digital Personal Data Protection Act, 2023;
- 1.4.2. Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”); and
- 1.4.3. Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
- 1.5. While We would strongly advise You to read the Privacy Policy in full, the following summary will give You a snapshot of the salient points covered herein:
- 1.5.1. This Privacy Policy details the critical aspects governing Your personal data relationship with ‘HeaLink’, having a place of business in Delhi. Your personal data relationship with HeaLink varies based on the capacity and medium in which You interact with Us/avail Our Services. You could be:
- 1.5.1.1. a visitor to the Website or any pages thereof (“Visitor”); or
- 1.5.1.2. a person who has an account with the HeaLink Application to avail of its Services (“Registered User”).
- 1.6. Based on whether You are a Visitor or Registered User, the type of data We collect and the purpose for which We use it will differ, and this Policy details such variations;
- 1.7. This Policy applies to all the Services provided by HeaLink through the Application;
- 1.8. This Policy is a part of and should be read in conjunction with Our Terms of Use;
- 1.9. This Policy will clarify the rights available to You vis-à-vis the personal data You share with Us;
- 1.10. Through accessing Our Application, You consent to this Privacy Policy, and consent to the usage and processing of information provided by You;
- 1.11. It is important to adhere to the definitions outlined in this Policy. However, in cases where a term has not been defined, the interpretation mentioned in Our Terms of Use shall prevail;
- 1.12. We provide a combination of in-app and aggregator Services and have tied up with Third-Party Service Providers and facilitated an aggregator platform for them to provide their Services. For this, We collect data on Our Application to be used by Us and shared with Third-Party Service Providers on a need-to-know basis; and
- 1.13. Our in-app services include booking appointments and teleconsultations with Third-Party Service Providers, creation of ABHA, uploading documents on the medical vault of the Application, and providing the facility of knowing the doctors and hospitals near You once You enter Your location.
2.INFORMATION WE COLLECT AND HOW WE USE IT
- 2.1.WHAT DATA WE MAY COLLECT FROM THE VISITOR
- 2.1.1. Your location;
- 2.1.2. How You behave on the Application, (what pages You land on, how much time You spend, etc.); and
- 2.1.3. What device do You use to access the Application and its details (model, operating system, etc).
- 2.2.WHAT DATA WE MAY COLLECT FROM THE REGISTERED USER
- 2.2.1. Your name, age, gender, phone number, e-mail address;
- 2.2.2. Your height, weight;
- 2.2.3. Your lifestyle, medical conditions (if any);
- 2.2.4. Your ethnicity, health, or sexual orientation;
- 2.2.5. Username or other relevant unique identifier;
- 2.2.6. Credit card/debit card/other payment mode information to facilitate payments for Our Services;
- 2.2.7. Your location unless You deactivate location services in the relevant section of the Application;
- 2.2.8. How You behave in the relevant product environment and use the features; and
- 2.2.9. What device do You use to access the Application and its details (model, operating system, etc.)
- 2.3.HOW AND WHY WE USE INFORMATION FROM VISITOR
- 2.3.1. We may use Your information to enhance Application interaction, assess your requirements and provide You with appropriate suggestions. ;
- 2.3.2. Visitors data is not used for retention purposes or for providing specialised services.;
- 2.3.3. The data provided by You is secured per industry standards. By accepting this Policy and Terms of Use, You consent Our access to Your anonymised data; and
- 2.3.4. If You submit Your details and give Us Your consent, We may use Your data to send You e-mails/newsletters, re-target HeaLink advertisements or re-market our Services using services from third parties like Facebook, Google, and Apple.
- 2.4. HOW AND WHY WE USE INFORMATION FROM REGISTERED USER
- 2.4.1. We collect this data in order to help You register for and facilitate the provisions of Our Services;
- 2.4.2. We utilize this data to track Your medical records, nutrition, weight, and fitness regimes;
- 2.4.3. We use the data of the device from which You access Our Application to distinguish the login information if there are multiple users using the same device;
- 2.4.4. We use this data to enable You to make payments for Our Services;
- 2.4.5. We use a third party to manage payment processing. We share only the required information with any third party for the specific purposes for which it is shared with Us. However, the terms and conditions and privacy policy of such third-party will be applicable to You;
- 2.4.6. We use this data for processing Your requests, enquiries and complaints, and customer services via [•];
- 2.4.7. We make use of this data to provide You with informative features and Services that are developed by Us from time-to-time;
- 2.4.8. We use this data for providing, testing, improving, or recommending the Services; and
- 2.4.9. Lastly, we use this data for analytics and reviews to improve the Services and to provide support to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law or anti-fraud activities/systems.
- 2.5. Healink is a cloud service provider. It does not provide any print facility via the Application to any Third-Party Service Provider. Should any Third-Party Service Provider take any prints or screenshots of any patient information or prescriptions, We shall not be held liable.
3.PUBLISHED CONTENT
- 3.1. Any content such as blogs, posts, articles, etc. posted/uploaded/ conveyed/published by Us on the public sections of the Application, as well as on various social media platforms and within Our ad campaigns is solely intended to optimize Our reach and visibility; and
- 3.2. We are not responsible for any actions taken by third parties with respect to such published content.
4.USE OF PERSONAL INFORMATION
- 4.1. We store any personal data We collect from You as long as it is necessary in order to facilitate Your use of the Services and for ancillary legitimate and essential business purposes – these include, without limitation, for improving Our Services, attending to technical issues, and dealing with disputes;
- 4.2. We intend to provide a better User experience through provision of Services on the Application including optimizing, or further developing/improving the operation of the Application;
- 4.3. You agree and acknowledge that Your personal data will be used by Us for the following purposes:
- 4.3.1 To contact You in relation to Service offerings on the Application, including pursuant to current or future collaborations with Third-Party Service Providers;
- 4.3.2 For payment, billing, and invoicing-related purposes;
- 4.3.3 General business and operating purposes, such as the administration, management, and operation of the business, including Third-Party Service Providers and Registered User interaction, responding to requests, customizing and improving Our Services;
- 4.3.4 For compliance with any judgment or order, or for fulfilling any obligation under any law for the time being in force in India;
- 4.3.5 To access the application via which You choose to upload Your documents on Our Application’s medical vault;
- 4.3.6 De-identified data may be used for research purposes, which includes but is not limited to, providing optimised services to You, enhancing Your user interface experience, improvement in business processes and decision making, accounting for patients’ preferences, monitoring demographic patterns and any other analysis which we may deem fit.
- 4.4. Your personal data will primarily be stored in electronic form. We may enter into an agreement with third parties to collect, store, and process Your personal data in compliance with applicable laws;
- 4.5. Anonymised data used for analysis, research, data mining, or similar purposes will not harm Your privacy. By accepting this Policy, You allow us to process Your data shared with us in accordance with our standard operating procedures, Terms of Use and this Privacy Policy;
- 4.6. We may retain Your personal data for legitimate purposes to comply with legal obligations, resolve disputes, and enforce Our agreements;
- 4.7. Your Account is immediately deleted once You delete Your account exclusively made on the Platform, except to the extent it is necessary to store the same under applicable laws;
- 4.8. Some of the examples in which We might delegate processing tasks to Third-Party Service Providers include record-keeping, data analysis, marketing support, payment processing, and customer service provision;
- 4.9. It is essential to note that in light of evolving changes related to privacy in India, We make every effort to ensure Our compliance with existing and forthcoming laws. Additionally, We will keep You informed if any new features are introduced in accordance with Government notifications; and
- 4.10. Healink is committed to upholding the protection of the User’s privacy. Any information gathered and shared under these circumstances within the Application will exclusively be used in accordance with the Policy as well as in compliance with relevant laws, rules, regulations, and standards;
5. TRANSFER OF INFORMATION
- 5.1. In the ordinary course of business, We may employ other Third-Party Service Providers to assist Us in providing certain components of Our Services in compliance with the provisions of this Policy. To do so, We may need to share Your data with them. Furthermore, You can select the Doctor, nutritionists, fitness trainers, wellness coaches, physiotherapists, , or any other wellness instructor whose services You want to use;
- 5.2. For instance, when You make Your selection, We will share Your basic details and profile with the chosen Doctor, nutritionists, fitness trainers, wellness coaches, physiotherapists, , or any other wellness instructor; and
- 5.3. Your medical vault records will not be shared with the respective Doctor, nutritionists, fitness trainers, wellness coaches, physiotherapists, , or any other wellness instructor, as the case may be, without Your consent and the consent pin.
6.THIRD-PARTY LINKS
- 6.1. We will not be responsible for such third-party websites or applications if You choose to access them;
- 6.2. If You provide any data to such website/application, please ensure You read their policies given that You will no longer be bound by this Policy in doing so; and
- 6.3. We may receive data whenever You visit a third-party link through Our Application which includes the date and time of Your visit to the third-party website, the web address or URL, technical information about the IP address, browser, and the operating system You use and, if You are logged into HeaLink, Your username.
7.COMPELLED DISCLOSURE
- 7.1. In addition to the purposes set out in the Policy, We may disclose any data that We have collected or processed from You if it is required:
- 7.1.1. To comply with Our obligations under applicable laws and other regulations, including protecting against and preventing fraud and other legal or information security risks;
- 7.1.2. To adhere to any current Indian laws or orders, or to fulfil claims of contractual or civil nature;
- 7.1.3. To address a medical emergency that poses a risk to Your life or the imminent health of any other individual; and
- 7.1.4. To serve other purposes for which We provide specific notice at the time of collection, and as otherwise authorized or for any other lawful purposes.
8.COOKIES
- 8.1. A cookie is data from a website that is stored within a web browser that the website can retrieve at a later time;
- 8.2. These cookies in no way give Us access to Your device. It is solely used to help Us collect information and to improve Our Services;
- 8.3. The default setting for most browsers is to accept cookies. However, if You choose to, You may be able to configure Your browser settings to decline or delete cookies. It is important to note that opting to delete or decline cookies may impact certain functionalities of the Application; and
- 8.4. We use a Third-Party Account (as defined in Our Terms of Use) to provide You with a smooth procedure for availing Our services. Such Third-Party Account may install their own cookies or files on Your device, gather data, or request personal information from You, for which Healink cannot be held responsible.
9.SECURITY OF YOUR PERSONAL INFORMATION
- 9.1. We implement commercially acceptable and certified standardised technology to ensure Your privacy. We have put in place several physical and technological measures to safeguard Your personal information;
- 9.2. Your password is Your first line of defence once You set up a HeaLink account. we recommend that You set a strong password, which shall remain undisclosed from Your end;
- 9.3. We use the email address that You provide via the Application to respond when You contact Us;
- 9.4. We have taken best possible steps for the security and protection of Your personal data and Our digital platforms including internal applications;
- 9.5. We shall not be responsible for any breach of security or the disclosure of personal data for reasons outside Our control including but not limited to Force Majeure (defined below), for instance, internet leaks, low security on User’s end, unreliable internet service provider, or data leakage
- 9.6. We are not responsible for the privacy standards of respective Third-Party Service Providers or any security lapses of their hardware or software, or any loss of data stored by them;
- 9.7. Any technical glitches or loss of mobile handset or security lapses of hardware or software or loss of User data available with the Third-Party Service Provider is out of HeaLink’s control and We shall not be responsible for such losses;
- 9.8. As there are Third-Party Service Providers being used to provide the Services, the privacy policy of these Third-Party Service Providers will be binding on You. In case of any update or change in their privacy policy, those changes shall also be applicable to You. During such updates, if there is a loss of data on their part, then HeaLink shall not be held liable; and
- 9.9. In case of any unauthorised access of Your handset that may lead to any breach or usage of Your data, shall not be the responsibility of HeaLink.
10.FORCE MAJEURE
- 10.1. “Force Majeure” shall mean and include any event beyond HeaLink’s control including but not limited to fire, flood, explosions, an act of god, computer hacking, computer crashes, breach of security, unauthorised access to computer data, and storage devices or due to governmental regulations;
- 10.2. We shall not be held responsible for the non-availability of the Application during periodic maintenance operations or any unplanned suspension of access to the Application that may occur due to downtime resulting from technical reasons, or for any reason beyond the Company’s control. If Your personal data might be lost in this process, We shall not be held liable. However, it will be Our best endeavour to resolve any such loss of personal data;
11.HOW DO WE SHARE PERSONAL INFORMATION:
- 11.1. By downloading this Application, You are providing Us with Your consent and We may share the data We collect from You to track Your visits and establish Your non-personal identity. We only use the information wherein Your personal identity is not disclosed.
12.CHANGES, ACCESS, CORRECTION 7 DELETION
- 12.1. We may amend this Privacy Policy from time to time. The use of information We collect now is subject to the Privacy Policy in effect at the time such information is used. If We make changes in the way We use personal information, We will notify You by posting an announcement on Our Application or sending You an email. You are bound by any changes to the Privacy Policy when You use the Application, or Service after such changes have been first posted;
- 12.2. You may request access, correction or updating, and deletion of the data by contacting developer@thirdai.co.in
- 12.3. You may note that deletion of certain data or withdrawal of consent may lead to cancellation of Your registration with Us or Your access to Our Services;
- 12.4. Based on technical feasibility, We will provide You with access to all Your personal and sensitive personal data that We maintain about You. We will perform a verification before providing You access to this data; and
- 12.5. You may opt out of Our marketing emails by clicking on the ‘opt-out’ link provided in the emails. However, We may still send You non-marketing emails about Your accounts or any other transactions with You.
13.GRIEVANCE OFFICER
- 13.1. If You have any queries or concerns with this Policy, please contact Our Grievance Officer. If You do not agree with the Policy, We would advise You to not visit/use the Application;
- 13.2. If You do not wish to receive email or other mail from Us, please email us at: developer@thirdai.co.in or contact Our Grievance Officer; and
- 13.3. Please note that if You do not want to receive legal notices from Us, such as this Privacy Policy, those legal notices will still govern Your use of the Application and the Services, and You are responsible for reviewing such legal notices for changes.
14.CONSENT MANAGER
- 14.1. The appointment of Consent Manager align with the regulations set forth in the Digital Personal Data Protection Act, 2023;
- 14.2. You have the option to grant, manage, review or withdraw Your consent to Us through a Consent Manager;
- 14.3. You may contact the Consent Manager at: developer@thirdai.co.in; and
- 14.4. The Consent Manager will be responsible to You and will operate in Your behalf, following the designated guidelines and obligations.